When you visit our websites (or subdomains) (the “Website”), make a reservation, contact us, purchase products from us or visit our property, we collect information from and about you. Some of the information we collect may be classed as personal data under data protection legislation, that is, “any information relating to an identified or identifiable natural person”. It may be collected any time you submit it to us, whatever the reason may be.

This Privacy Statement describes which personal data is collected and for which purposes this personal data is processed by Wroxall Abbey Hotel & Estate. It also states which rights you have under applicable data protection legislation.

MUST READ SECTIONS: We draw your attention in particular to the section entitled “Your Rights.”

COLLECTING YOUR PERSONAL DATA

Wroxall Abbey Hotel & Estate collects information about you in the following ways.

Information you give to us. This includes personal data collected:

Through our Website when you register, login, commence or complete an online transaction to use our products and services.

When you contact our reservations team to make a booking or use the facilities at any of our properties. Facilities include, but are not limited to, meeting room, Spa, bar and/or restaurant, function rooms.

When you have provided your consent, in order to:

sign up to any of our loyalty programmes;

subscribe to any of our marketing communications

complete customer surveys, enter competitions or provide feedback.

When we do business with you, which will usually include:

Full or partial contact details including names and addresses (including business details if you are making a corporate booking), telephone and email details.

If you have special requirements then it may also be necessary to collect details about diet or disability or any other preferences that you may have.

Car parking arrangements at our properties may also make it necessary for us to collect your car registration number for your visit to us.

We collect payment card information from you should you choose to use this form of payment for purchasing or guaranteeing use of our products and services.

From our overseas guests we may also collect passport details.

Information Automatically Collected. This includes information and personal data collected:

Through our Website. We automatically log information about you and your computer or mobile device when you access Website. The information about your use of the Website comprises http header information which your browser transmits to our webserver, information collected through the use of cookies and log information. For example, when visiting Website, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Website, pages you viewed, how long you spent on a page, access times and information about your use of and actions on Website.

Through CCTV at our property. We operate CCTV systems at our property. These are in operation and video recordings may be made. This activity is carried out for security and service reasons for the better management of Wroxall Abbey Hotel & Estate’s property and security for all its clients and staff.

WHY DO WE PROCESS YOUR PERSONAL DATA?

We use the information we collect about you to process your bookings, answer your queries and provide our hotel and restaurant facilities and services. With your consent, we will contact you via our marketing and sales channels (email/ phone/ post) about other related products and services we provide which we think may be of interest to you. Our marketing communications are generally sent by email but we may sometimes use other methods of delivery such as by post.

We mainly collect, store and process personal data when you visit or have visited Wroxall.

When you make a reservation, you will have to provide us with your name, email address, phone number, the dates you are staying with us and a credit card or other payment information as applicable. We use this personal data to process the reservation, for billing purposes, and to allow us to communicate with you about your reservation. When you stay, we will collect personal data about your preferences, use of our services, and location.

We may at each of the stages outlined above use your personal data but only when and to the extent the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Where you have provided your consent.

For your convenience, we have made an overview of activities that involve the processing of your personal data, and the corresponding legal basis/legal bases that allow us to process this data:

Purpose/activity

Legal basis

1.

First of all, we store the personal data you provide to us in our systems for administrative purposes.

· consent, where required

· enter into or perform a contract to which you are a party

2.

Government regulations require us to ask you to provide us with certain information when you arrive at Wroxall Abbey Hotel & Estate. This may include information such as: birth date, nationality, place of residence, date of arrival and profession.

· compliance with a legal obligation

3.

We will have to verify your identity when you arrive at Wroxall Abbey Hotel & Estate. We will use your passport or other identification document. We will not store a copy of your passport, except to the extent permitted by law.

· enter into or perform a contract to which you are a party

· for the purposes of our, or a third party’s, legitimate interests, including keeping our records up to date

4.

We store your personal data in our database(s), also after your transaction has been completed and after you have stayed at Wroxall Abbey Hotel & Estate to the extent required by law, and if you have signed up a loyalty programme, to be able to contact you and welcome you again in the future.

· compliance with a legal obligation

· for the purposes of our legitimate interests, including:

· keeping our records up to date

· managing our on-going relationship with you

5.

We process your booking, howsoever made directly via our website or via a third party (online) travel agent.

· enter into or perform a contract to which you are a party

6.

We offer and provide services and products you request from us or which we may think you are interested in, via email, telephone or other media. These marketing communications contain commercial offers and news of Wroxall Abbey Hotel & Estate and related third parties. We use the email address you provide to send the newsletter to. If you no longer wish to receive the newsletter, you can unsubscribe and we will no longer send you these marketing communications.

· consent, where required

· enter into or perform a contract to which you are a party

· for the purposes of our, or a third party’s, legitimate interests

7.

We use credit card data or other payment data for invoicing purposes.

· enter into or perform a contract to which you are a party

8.

If you would like to park in one of our parking areas we may collect your license plate number for security purposes.

· enter into or perform a contract to which you are a party

9.

We endeavour to provide a high level of security of both the information we store as well as our facilities, (IT) systems and premises, by means of encryption, physical security measures, passwords, company procedures and policies and professional IT support. Personal data may be processed in this context by Wroxall Abbey Hotel & Estate and its vendors.

· for the purposes of our, or a third party’s, legitimate interests, including:

· maintaining appropriate physical and IT/network security

10.

We endeavour to prevent our services and facilities (properties) from being used for illegal purposes, of any kind. Personal data may be processed in this context by Wroxall Abbey Hotel & Estate and its vendors, such as through CCTV surveillance.

· vital interests

· for the purposes of our, or a third party’s, legitimate interests, including:

· protecting you during your stay

11.

We engage in activities required for compliance with legal obligations, third party claims or requests from public authorities, such as (i) the mandatory storage/containment of certain information because of a criminal investigation, (ii) requests from third parties for access to information (iii) any further instructions from third parties, such as supervisory authorities, that involve data processing.

· consent (if required)

· enter into or perform a contract to which you are a party

· for the purposes of our, or a third party’s, legitimate interests

· compliance with a legal obligation

12.

If you have special requirements then it may also be necessary to collect special categories of personal data in relation to diet or disability.

· consent

SHARING YOUR DATA

We may share your personal data as follows:

Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.

Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as payment processing, information technology and related infrastructure provision, business support (operational and administrative), customer service, the processing and delivery of marketing communications to you, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data. Third parties are subject to confidentiality obligations and may only use your personal data to perform the necessary functions and not for other purposes.

We may share some or all of your personal data with our affiliates, in which case we will require our affiliates to comply with this Privacy Statement. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.

Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Privacy Statement; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

We do not share your data with any third parties outside of the above processing arrangements and we do not share your data with any business external to our group for their own marketing purposes. From the data we collect, you should only ever receive marketing communications from our own brands and hotels.

YOUR RIGHTS

The GDPR provides the following rights for individuals:

Right to revoke consent

If we process personal data on the basis of your consent, you have the legal right to revoke such consent at any time. We will then cease the relevant processing activity going forward.

Right of access to your information

If you want to know what personal data we have collected or process about you, you may request us to provide a copy of your personal data by sending an email to reservation@wroxall.com We will ask you to identify yourself. We will not provide you with a copy of your personal data to the extent that the rights and freedoms of others are or may be adversely affected.

Right to rectification and erasure of data, and restriction of processing

If you believe that our processing of your personal data is incorrect, inaccurate, unlawful, excessive, incomplete, no longer relevant, or if you think that your data is stored longer than necessary, you may ask us to change or remove such personal data or restrict such processing activity, by sending an email to reservation@wroxall.com

Right to data portability

You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format, in accordance with Article 20 of the General Data Protection Regulation.

Right to object

You have the legal right to object, on grounds relating to your particular personal situation, at any time to processing of your personal data. Furthermore, you have the right to object at any time to our processing of your personal data for direct marketing purposes or to profiling. You can do this by either (i) opting out by using the option we provide in the relevant direct marketing message (e.g. an email newsletter), or (ii) by sending an email to reservation@wroxall.com or (iv) writing to:

Wroxall Abbey Hotel & Estate

Birmingham Road

Wroxall

Warwickshire

CV35 7NB

For the sake of clarity: without prejudice to the foregoing we are at all times entitled to send you messages that do not constitute direct marketing, i.e. service messages.

General information relevant for all requests and queries

Nothing in this Privacy Statement is intended to provide you with rights beyond or in addition to your rights as a data subject under applicable mandatory data protection law.

We will use reasonable endeavours to respond to your request or query within one month. We are entitled to extend this term by another two months if the complexity of the situation so requires. If your request is manifestly unfounded or excessive we may either (i) charge you a fee, or (ii) refuse to process your request. With respect to access requests we may also charge you for extra copies. If we decide not to honour your request or answer your query, we will explain our reasons for doing so in our reply.

PROTECTION AND STORAGE OF YOUR DATA

We have used and will continue to use reasonable endeavours to protect your personal data against loss, alteration or any form of unlawful use.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

COOKIES

The Website uses various cookies. We may track and record your use of our online services, either through cookies or via other means. Cookies enable us and others to monitor your browsing behaviour.

RETENTION OF INFORMATION

We will only retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Statement. This may be up to 4 years, unless a longer retention period is required or permitted by law (which is typically the case in the context of our obligations under tax law).

Should you choose to unsubscribe from our mailing list, please note that your personal data may still be retained on our database to the extent permitted by law.

GENERAL

We are committed to resolve any complaints about our collection or use of your personal data. In case you have any questions in relation to this Privacy Statement or our practices in relation to your personal data you may send an email to reservation@wroxall.com We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.

We have done our best to make sure that this Privacy Statement explains the way in which we process your personal data, and rights you have in relation thereto. We may change this Privacy Statement from time to time to make sure it is still up to date and we will notify you if we make any material updates. We may also notify you in other ways from time to time about the processing of your personal information.